Our firm manages assets for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value.
Our firm sponsors and offers a wrap fee program. Our wrap fee program allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Because our firm absorbs client transaction fees, an incentive exists to limit trading activities in client accounts. Custodial transaction costs, however, are not included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the client to their chosen custodian. Depending on the client’s account or portfolio trading activity, clients may pay more for using our wrap fee services than they would for using our non-wrap services.
Prior to receiving services under the Program, clients are required to enter into a written agreement with BFG setting forth the relevant terms and conditions of the advisory relationship. Clients must also open a securities brokerage account and complete a new account agreement with a “qualified custodian” as that term is described in Rule 206(4)-2 of the Advisors Act.. We currently recommend our clients use Schwab Advisor Services, a division of Charles Schwab and Co. (“Schwab”), but other custodians may be used in certain circumstances.
Our Wrap Advisory Services Wrap Asset Management: As part of our Wrap Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
Fee Schedule BFG charges an annual advisory fee that is agreed upon with each client and set forth in an agreement executed by BFG and the client. The maximum annual fee charged for this service will not exceed 2.00%. Fees to be assessed will be outlined in each client’s Program Agreement. Annualized fees are billed on a pro-rata basis monthly in advance based on the average daily average value of the previous month, based on the value of the account(s) as provided by third-party sources, such as pricing services, custodians, fund administrators, and client-provided sources when necessary. Fees are negotiable and will be deducted from Client account(s) by BFG and/or the chosen Sub-Adviser or SMA. Adjustments will be made for deposits and withdrawals during the month. In rare cases, BFG will agree to directly invoice. As part of this process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly

showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; 5 b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, legend urging the comparison of information provided in our statement with those from the qualified custodian will be included.
Factors upon which a different Program Fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. The Program Fee charged by the Firm will apply to all of the client’s assets in the Program, unless specifically excluded in the client agreement. Although BFG believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms.
For the sub-advisory services rendered to our clients, our firm compensates third party investment advisory firms or individual advisors a percentage of the overall investment advisory fee charged by our firm. The advisory fee pad shall not exceed he fee published for this service. The terms and conditions under which the client shall engage the third-party investment advisory firm or individual advisors shall be set forth in a separate agreement between the client and the designated third party.
Clients may make additions to and withdrawals from their account at any time, subject to BFG’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets at any time on notice to BFG, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. BFG may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications.
Other Types of Fees & Expenses: In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark- downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees.
Wrap Fee Program Recommendations Our firm does not recommend or offer the wrap program services of other providers.